ML19044A476

3150-AK12 PM Responses OGC Comments Draft Dfr FRN for NAC CoC Amendment 6 062518

ML19044A476
Person / Time
Site:	07201015
Issue date:	06/25/2018
From:	Robert Macdougall Office of Nuclear Material Safety and Safeguards
To:	Garrett Henderson NRC/OGC
MacDougall R
Shared Package
ML19040A003	List: ML19044A453 ML19044A454 ML19044A455 ML19044A457 ML19044A458 ML19044A459 ML19044A460 ML19044A461 ML19044A462 ML19044A463 ML19044A464 ML19044A465 ML19044A466 ML19044A467 ML19044A468 ML19044A469 ML19044A470 ML19044A471 ML19044A475 ML19044A476 ML19044A477 ML19044A478 ML19044A479 ML19052A010
References
RIN 3150-AK12, NRC-2018-0075
Download: ML19044A476 (3)

Text

From: Macdougall, Robert To: Henderson, Garrett

Subject:

RE: Draft DFR FRN for NAC CoC Amendment 6 Date: Monday, June 25, 2018 12:56:00 PM Attachments: NAC CoC Amndt 6 DFR FRN (GDH-RDM comments) 062518.docx Hi, Garrett, Thanks for getting back to me with your comments and suggested edits - and no need to apologize; were all busy.

Attached are my responses to your comments and edits. Although we might still need to call a working group meeting if you think it necessary, I think our differences are minor enough to enable us to avoid one. Im hoping that if my responses in the attached make sense to you - and to you, Bernie, and you, Carol -- I might be able to submit a clean draft, along with a draft proposed rule conforming to these changes, in a package for everybodys concurrence/NLO to proceed to the next step.

If anybody has any objections to my proposed path forward without a meeting, please let me know.

Thanks in advance, Rob From: Henderson, Garrett Sent: Monday, June 25, 2018 9:38 AM To: Macdougall, Robert <Robert.MacDougall@nrc.gov>

Subject:

RE: Draft DFR FRN for NAC CoC Amendment 6 Good morning, Rob, My apologies on not replying to your email sooner, I was out last Thursday and Friday. Also apologies are due for my failure to return my comments on the FRN in a timelier manner. It turns out that I have been assigned to two separate working groups on regulations pertaining to casks and was provided an FRN to review for each. I conflated the two.

I have now reviewed your FRN and identified a few minor issues that I dont think will be difficult to resolve (text tweaks, missing citations, etc.), and one more medium level issue that might need some discussion, namely that I dont believe the alternative actions section accurately reflects what would happen if this amendment was denied. I set forth my opinion on the issue in the comments to the attached draft. Give it a read and let me know your thoughts.

Thanks for your patience.

-Garrett From: Macdougall, Robert Sent: Wednesday, June 20, 2018 6:35 PM

To: Henderson, Garrett <Garrett.Henderson@nrc.gov>

Cc: White, Bernard <Bernard.White@nrc.gov>; Gallagher, Carol <Carol.Gallagher@nrc.gov>

Subject:

RE: Draft DFR FRN for NAC CoC Amendment 6 Hi, Garrett, Just got back yesterday from more than two weeks out of the office, and wanted to check in with you. Have you been able to make any progress on this bad boy, and if so, do you think we need to have a working group meeting to hash out anything?

Rob From: Henderson, Garrett Sent: Wednesday, May 30, 2018 4:45 PM To: Macdougall, Robert <Robert.MacDougall@nrc.gov>

Subject:

RE: Draft DFR FRN for NAC CoC Amendment 6 Hi Rob, Pleased to be aboard. I will review and try and turn it around next week. Once Ive given it a once over we can figure out if we need to convene the super team.

-Garrett From: Macdougall, Robert Sent: Wednesday, May 30, 2018 4:43 PM To: Henderson, Garrett <Garrett.Henderson@nrc.gov>

Cc: White, Bernard <Bernard.White@nrc.gov>; Gallagher, Carol <Carol.Gallagher@nrc.gov>;

Morgan-Butler, Kimyata <Kimyata.Morgan-Butler@nrc.gov>

Subject:

Draft DFR FRN for NAC CoC Amendment 6 Hi, Garrett, I understand that youve been assigned to our working group on this CoC rulemaking. Welcome aboard. We were hoping it would be you.

While Bernie and Carol and I were waiting for this moment, I asked them to review and revise my template-derived draft Federal Register Notice for the direct final rule for this rulemaking, figuring that you could start with a version theyve approved. That version is attached. If youd like for me to convene our working group to discuss it, Ill be happy to do that, but you can also review it first and then decide whether we need to meet. If you conclude that we dont, send us your markup, and if none of us think we need to discuss anything youve revised. Ill copy and paste from your markup to complete and circulate for everybodys review the FRN for the proposed rule. Once I have everybodys e-mailed approvals of the proposed rule FRN draft, Ill put the package together, get my BC Kim to approve, and send it electronically to Bernie and Carol for their concurrences and to OGCs

RIDS address for your NLO review. Sound like a plan? Well, maybe at least in theory.

Let me know your druthers, Rob Robert D. MacDougall Project Manager Materials Rulemaking and Project Management Branch Division of Rulemaking, NMSS 301-415-5175 T-4A26 Mail Stop T-4B72